FCC Proposed Rulemaking about paid employees and emergency drills

It seems the End of the Ham Radio Universe for the "no business" purist or so you would think, but Emcomm has been a part of Ham Radio since before WW2 in one form or another. ARES was born in the 1930s with the ARRL which grew out of the idea of "relay" stations in the 1910s so the idea of helping your fellow man (woman) is the basic concept behing Amateur Radio.

WERs during WW2 was instituted for EMCOMM but with the end of WW2 the restarting of Amateur Radio had a profound effect on EMCOMM with Gen. Curtis LeMay (Ham Radio Op call not remembered) who stated the hams had the best if the most widespread communication system in the world.

RACES was born in 1952 with some problems written into it. For most hams here, the RACES was cold war program with idea to keep communications open in the event of nuclear war. First, it had a backdoor open to non hams, you see, if a locality could not find a ham operator to be a RACES OFFICER, then the local office of Civil Defense could appoint a person with a second-class phone to the position and voila, FAUX-HAM was made. We had fake hams running wild and abuse of the Airways by folks who did not possess a ham ticket nor they get one, yes it was the code. Second, it was hard to manage since DOD CD office was put in charge and the ham radio factor was poorly known to the CD folks just as the Emergency Management today sometimes have a differing view of ham radio.

RACES was revisited and the HAM TICKET rule was re-instated much to the chagrin of the FAUX-HAMS and CD directors who then had to recruit hams to join RACES. Some RACES groups flourished and some floundered during the 1970s and 1980's when CB and Cellphone showed up along with trunked systems. The confusion and complex communication modes now confuse the Emergency Management folks since most have very little exposure to the Technology (Why does it work) how-tos. I had a Emergency Manager tout his Satellite Phone and brags how it will replace the hams only to have the EM Manager yelling for hams during Katrina.

Now the Hospitals and CD folks are learning a sad lesson, a vanilla flavored radio will work where a 3000 dollar trunked radio will fail like in Katrina. However for you Hams hollering for Part 90 Volunteers, try to get Frequency Coordination for Part 90 radio/services, sorry, business band radio works great in fair weather but for Emegency Comms, the attraction of Ham Radio is the different frequency bands, each with their own physical characteristics, myriad of available frequencies, ease of operation of equipment (appliance operation is the norm now) and availablity of equipment/cost.

I can not see the genie going back into the bottle since EMCOMM has become a big business, ARES is an ARRL program but seriously lacks controls over misuse. RACES is the best idea but I am afraid ARES is in competition since the DHS (FEMA administers RACES) and ARRL wants to keep control but on this one I support the elimination of the waiver drill rule based upon the adoption of allowing Hospitals and other disaster orgs coming under the RACES banner if paid ops are allowed, this would limit the drills and ensure some accountability.

Is it perfect? No but the EMCOMM is a part of Amateur Radio and it isn't going away, sorry fellows but thems are de breaks.

 

Actually Civil Defense was on NON-ham frequencies. Where I was radio officer (and I was a ham) our CD station operated on 1775.5 khz, just below the 160 meter band. We also had CD frequencies on VHF, and used the Gonset Gooney Box for those. They, too, were outside ham radio frequencies.

In fact, a ham license was NOT the license required to operate one of those stations, since they were not ham stations. They were government stations. Consequently a First or Second Phone license was required for operation and maintenance, and a Third Class Phone License (not the Third Class phone permit) was the minimum to operate. The third, though, could not make adjustments to the transmitter.

Many of these stations were also licensed as ham club stations. There was an agreement with the CD organization that hams could have access to the equipment - but only on ham frequencies - if they would provide some help with maintenance. Our radio club agreed to that.

With a Second or First Class ticket holder on scene, anyone could 'operate' the CD station on CD frequencies. But all he could do was flip the Plate switch to transmit, or to receive. He could not make adjustments in modulation, redipping the final, or anything that could affect the legal operation of the station.

Likewise, when the station equipment was operated on amateur frequencies, there had to be a control operator "in control." In those days, the third party guest was not permitted to do anymore than above - flip the T-R switch. And a lot of people believed it was illegal to allow an unlicensed person to do even that much, so the control operator would flip the switch for the third party.

I don't know what happened to those old CD stations. Some of them may still exist. But as a CD operation, they were not on the ham bands.

As a CD officer, I had a Gooney Box I brought home. It was the one on six meters. I had ham band crystals for it, so I used it on six, under my ham call sign. But I could retune it quickly to the CD channel, which, as I recall, was on 49 mhz. I'm not sure of that. At times I also borrowed a 2 meter version, and I think the CD frequency was 143 mhz something, but again, it has been many, many years. Memory is old!

I would imagine some of these frequencies are still available to government agencies. Certainly MARS has many frequencies just outside the ham bands. So does CAP. So does SAR. And so should ARES/DHS/FEMA.

Ed

 

Third class phone was an operator ticket but Louisiana had a rule only 2nd Class or General Class ham could operate their CD Radios, we still have the radio around, SHARES which are FEMA but as radio stuff goes hot and cold, so has the radios, there are several 2 & 3 MHZ freqs in use but trying to get the CD folks to use them, hell most CD folks don't know why a Radio wave comes off an antennnas much less the meaning of the word propagation!

Most Ham back in the day were "Technicians" and held a phone license to work on transmitters (before deregulation) but most Radio Techs were not hams so they volunteer for the "Radio Job" to play ham. Any ham back then could pass a phone ticket with his or her eyes closed, but the code did keep some techs out. (But I do not want to go to a code-no code debate) (Neither CB arguement)

The same problem we have today, who can operate the radio, the hospitals want it and some don't. The DOD Freqs have a problem is that VFOs are hard to use (Hams do have some training on VFOs) so Frequency agile radios off the Ham Bands are not really wanted or desired. I can transmit on MARS Freqs (MARS MEMBER) but do you want Frequency agile radios running loose? We hams do understand Freq and Usage so that is one reason Amateur Radio has some attraction and currency. In the old days RACES was not perfect but it kept things in check and Ham Radio should offer assistance to justify the frequencies, you may not agree but if the service doesn't pays it dues, it may find itself paying with a loss of frequencies.

So are ham freqs, DOD, NTIA and anything else they want to assign, however ham radio doesn't exist in a vacuum and I was in Katrina and HAM RADIO shone bright. A bright star of Amateur Radio is what I believe we need to preserve the playground of Hobby Frequencies but if we become a stumbling block, guess what, GONE. Amateur Radio has these things:

1. Multiple Frequencies (No coordination required (repeaters excepted))
2. Standard Licensing
3. Standard Equipment
4. Multiple mode Operation
5. Technical Expertise of hams as a group
6. Can a part 90 radio be freq agile?

Sorry, ED, I have to say the plusses outrule the minusses on this one. Have you filed your comments with the FCC, I did and my suggestion is that RACES is the appropriate way to go with this one. Read the comments.

 

I don't agree that there's more benefit than potential harm from injecting "emcomm" into "HAM" this way. But, to your point about it seeming to be inevitable, IF that's true, then the only way I find acceptable is to have the system overseen by people who primarily are licensed radio hobbyists with the broadest sense of the workings of the Amateur Service.

NOT the other way around, where "hospital HAMs" form their own clique and show up whenever their employer tells them, doing whatever their employer considers a drill, and then leaving when it's time to punch the clock for the day.

 

RACES is the answer to the non-problem. Ahh, but the ARRL did it's level best to downplay RACES role in governments' needs to access the amateur radio service. Ironic isn't it how the league's own power play attempts failed and created this problem?

RACES already creates limits on who can participate in drills, their frequency, and other requirements for government use of the amateur radio service. It was designed to allow "interoperability" so to speak. But the league started pushing their dog, ARES in the race, touting "when all else fails" spew to governments. And just like governments will go out and drop 60 million dollars on a new trunking system because Ma M tells them they "have to", many of them buy in not knowing exactly what their needs are and what they are really getting and thus, we find ourselves at this point.

The next step to preserving our service is NOT to run off governments, hospitals and other public safety and health entities from the benefits of working within the amateur community but to elmer them as we would any other ham. RACES is the answer, a modernization of it would fill the gap, ensure that our service doesn't become a replacement for backup part 90 radios, but doesn't eliminate us from the picture either and allows us to serve our communities in times of need as we always have, voluntarily, since the dawn of the wireless age. But you'll never see the league tout RACES because it isn't something that puts money in their coffers or something they can control.

 

Amen brother, N4XTS, you said what I have been hinting at, As EC and RACES OFFICER I see RACES as the Official end of Ham Radio with rules that need to be reformed to reflect modern day reality. RACES grew out of WERS and COLD WAR nuclear war (Hams might survive) mentality but ARES is too loosely organized around the ARRL field organization which is a CT non-profit organization to promote Ham Radio. Local and State Laws on volunteers in the 50 States and terretories are different and RACES works under FEMA/DHS fits the bill, is a federal set of rules on PART 97 Emergency Operations which gives the folks desiring to use Ham RAdio a set of rules, not guidelines which removes the onus off the individual ham when a served agency wants something done.

RACES should be modernized, revised for the realities of today's operations in EMCOMM with and then placed under DHS with a set structure within Emergency Management/DHS. This would place limits on its use and prevent abuse by folks wanting to get around Part 90 backups. In an earlier post, I spoke about the "Wannabe" hams who got a commercial phone ticket and then got in RACES as a "communications volunteer" bypassing the Ham Test and still using Ham Frequencies to play "Ham Radio". Wannabes are prevelant in any profession or avocation and yes back in the day when the code barrier kept out some folks, they looked for a way around.

Ham Radio has discipline enforced by strict licensing and that is one thing a GOVT PERSON recognizes is the chain of command and discipline. Part 90 radio is not organized to the degree ham radio is and with the flexability of Ham Radio, it naturally attracts folks who recognize its strengths.

We (Amateur Radio Hobbyists) need to recognizze to keep the hobby healthy and alive with folks interested in Amateur Radio, the public eye needs to be aware of US and what we can do, lets do it and get the recognition from both the Govt and private industry along with shedding the image of being just high powered CBs in the eyes of the public. AND PUBLIC IMAGE IS EVERYTHING.

 

I have to wonder, if all these hospitals and other businesses can't keep their Part 90 systems up and running, what makes anyone think they can keep the Part 97 systems in any better working condition?

My gut tells me that it's a people problem, not a hardware problem.

So if a system is prone to failure - what do they do? Put the same people in charge of another system? Doesn't make any sense.

What has made amateur radio valuable for emergency and disaster relief over the past century, is the PEOPLE, their aptitudes, experience, competence, resourcefulness, etc.. that comes about from a love of radio communications, self-training, technical investigations, and engaging in the radio art. Does giving a license to an employee, because it is expedient for the employer, and making him key a mic as part of his job once or twice a year provide the same value? I don't think so.

It's not the hardware that needs backup - it's the people.

 

Much of this push for morphing amateur radio into professional backup radio seems to revolve around the idea that Part 90 systems are unreliable, prone to failure.

Seems to me that it would make more sense (and would serve the public interest much better) for the FCC to fix Part 90, instead of screwing up Part 97.


Part 97 isn't what is broken. If it ain't broke, don't fix it.

 

Most part 90 systems are so complex that only specialized person (trained in the product) (a high priest of technology) which explains why the 1st and 2nd Class Licenses morphed into GROLs and most radio techs no longer even mess with them since unless you work on Marine VHF or HF gear it is no longer required. A certificate from the manufactor gives you the work authority on their equipment. Every Part 90 operator is an APPLIANCE OP in every meaning of the word. Who knows about SWR, Antenna Resononace, OHM's Law not to mention Part 90 Coordination. Get the picture, the hams are seen as the last of the cavemen who know how it works, in KATRINA, on Saturday we were geeks with radios who could talk to South America, on Tuesday Morning after landfall and flood, Hams were looked at as DEMI GODS who could like Prometheus, deliver fire. No time to explain technology to the Mortals, I was pressed into service and carted off like a Greek God along with several other Hams to work our magic. No Part 90 magic here.

In KATRINA the complex stuff failed due to switching gear and main hubs going underwater, our stand alone systems worked because they are stand alone.

Can you harden a Part 90 system, sure, with a GOLDEN CHECKBOOK and a stupid taxpayer which exists only in some folks mind. Part 90 systems are chocked with bell and whistles along with trunking and interconnections that when the controller fails, voila it fails and nobody operating the system knows how to fix it, call FATHER TEKNOS, the High Priest of Technology at $275 per hour. He ain't making house calls during KATRINA or 9-11.

So feel flattered, you might be counted amongst competent hams, demi-gods of the technologic world.

 

It ain't broken just the FCC hates to waste time with waivers. And yes part 90 systems are prone to failure but the Money dogs (M & COMPANY) make a bundle out of this.

ARRL makes money off ARES but RACE is in Part 97 so go figure.

 

In case you were unable to find this like I was until helped...............

From the March 13, 2010 Meeting Minutes of the ARRL Executive Committee.

"4.2. Mr. Sumner and Mr. Imlay have presented to FCC staff the ARRL’s position on additional language for §97.113(a)(3) of the FCC Rules. The addition would provide for a narrow exception to the prohibition on communications on behalf of an employer in order to permit participation in emergency preparedness and disaster drills. They spoke to advisors to all five FCC Commissioners and to the Chief and a Deputy Chief of the Public Safety and Homeland Security Bureau. The FCC has received and has put on public notice a request from the American Hospital Association (AHA) for a blanket waiver to permit hospitals seeking accreditation to use Amateur Radio operators who are hospital employees to transmit communications on behalf of the hospital as part of emergency preparedness drills. After discussion the committee agreed that the ARRL will file comments supporting the waiver to the extent that it is consistent with the ARRL’s proposed modification to §97.113(a)(3), and will ask AHA to clarify its waiver request to bring it into conformity with that policy."

 

No to paid " Hams "

NO NO NO
More worthless Government employees on MY ham bands. NO NO NO
If your not defending the US then why are you drawing a government check ?
Please read the Constitution if you don't understand the above statement.

 

Public Benefit

You know it says Public and I believe that is where most of the confusion comes in. We are the public and our frequencies maybe under attack but if you feel that we as Hams must justify our sole existence by providing emergency communications to your neighbors then you have missed the whole point and meaning of "Ham Radio".

But too under the current administration I am sure they could care less about a hobby as old as this and would love to make some big changes to show their power and ability to do or change what they want no matter what the people of this country wants or thinks. Heck look at this new health care reform being crammed down our throats. Plus I am sure they would want to make sure we don't forget it and learn something from it. Sorta like teaching a child who can't think or reason for it self.

But the fact remains that Part 97 is the rule and it does say that AR is a non-commercial form. What more needs to be said than that?

If we are going to loose our privileges because the general public doesn't see AR as a useful valid hobby that has created and help create so many different forms and modes of communication then the whole Part 97 needs to be rewritten to reflect what the public wants.

But so you know I totally understand your point which is self preservation if I am not mistaken. Which is a very good point and something we all need to keep in mind. But if we loose a great hobby such as this over something of this nature then we didn't have a leg to stand on anyway and all was doomed from the beginning.

DE WW5RM

 

I am a fairly new ham so, I dont have a lot of history to draw on. There may be long standing arguments I'm not aware of. But, here's what I have personal knowledge about.

As soon as I passed my tech exam I got myself a 2meter rig. Things were pretty dead on the local repeaters. Except for the weekly check in on the county Auxiliary Communications Service (ACS) net. The net operated every Monday night. They held some training in message handling etc. I thought it would be a good thing to have at least a little training in how to be an effective part of the emergency communications plan. After spending 20 years in the military, I am no stranger to getting training for "Just in case you need it". The problem is, I am a Deputy Sheriff. I am a county employee. My job has absolutely nothing to do with my hobby. I have never transmitted on any ham band while on a paid status. However, the ACS (RACES) functions are considered as beneficial to my employer. So, I am not allowed to participate in any drills or other "On-Air" activities that the ACS holds.

I don't see how allowing someone like me to participate in drills, and practice skills that may be needed someday, violates the spirit of the regulations. I don't want to operate an amateur radio for the county as part of my job. I want to operate as a service to those in need, when they need it. Regardless of who my day-to-day employer is.

 

If you can do it within the rules you're OK. It's all black and white in the rules. That is, can you do it with solely a personal aim, without pecuniary interest, is it voluntary, is it non-commercial, are you not receiving compensation for the ham communications, and there isn't another radio service you should be using, then it's OK.

The problem now is that there's a flood of people out there who are not using ham radio for personal aim, their employers have a pecuniary interest (government grant money or just because it's cheaper), it's a job requirement not voluntary, commercial entities want to use it, employees are being paid to do it, and there are other radio services that are intended for what they're doing. Just the opposite of what amateur radio is supposed be, on every point!

There are lots of organizations out there who DO want their employees to use ham radio as part of their job, either they don't want to deal with volunteers, or the Part 90 systems they are supposed to be using are too expensive or too complex for their needs. Once you start carving out exceptions for one such non-ham group, such as hospitals, to use ham radio as a substitute for Part 90, then it's only a matter of time before the whole shebang is being used for routine matters not just emergencies and disaster relief, and then quickly after that, the unlicensed use will creep in. It's already started - the Indianopolis Police department situation, for example. Ham radio quickly became a back-channel way of doing routine communications without going through their dispatcher.

The Waiver process sets up a mechanism to prevent abuse and exploitation of ham radio and filter out inappropriate use. That's why the hospitals want to do away with waivers, so they can abuse and exploit ham radio.